We welcome the SEC’s proposal in general and believe that it will benefit foreign issuers by reducing regulatory burdens, resulting in cost savings for non-US listed companies and those seeking listings in the US market.
We note, however, that the SEC’s proposal would only eliminate US GAAP reconciliation for companies that publish financial statements in accordance with IFRS as published by the IASB. The IAS Directive (EU-Directive 1606/2002 of 19th July 2002) requires companies whose securities are admitted to trading on a regulated market of any EU Member State to prepare their financial statements according to IFRS. Although there is no material difference between IFRS as adopted by the EU and IFRS as published by the IASB, under the current wording of the SEC proposal, for EU companies (i.e. the majority of foreign issuers listed in the US), the reconciliation requirement would not be removed. We therefore suggest that the SEC consider eliminating the reconciliation requirement also for companies that publish financial statements in accordance with IFRS as adopted by the EU, in order to maximise the benefits of this welcomed proposal.
